The defendant is charged [in count __]
with money laundering in the first degree. The statute defining this offense
reads in pertinent part as follows:

a person commits the crime of money
laundering in the first degree when (he/she) (exchanges / receives in exchange),
in one or more transactions, one or more monetary instruments derived from
criminal conduct constituting a felony and of a total value exceeding ten
thousand dollars, for one or more other monetary instruments [or equivalent
property,] with the intent <insert as appropriate:>

to conceal that the
exchanged monetary instrument or instruments (or equivalent property) is derived
in whole or in part from the criminal sale of a controlled substance.

that the exchange
aid a person in the criminal sale of a controlled substance.

that the exchange
aid a person to profit in the sale of a controlled substance.

that the exchange
benefit a person from the criminal sale of a controlled substance.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Exchange of
monetary instrument The first element is that the
defendant (exchanged / received in exchange) any monetary instrument with a
value exceeding ten thousand dollars for one or more other monetary instruments
[or equivalent property].

"Monetary
instrument" means coin or currency of the United States or of any other
country, travelers' checks, personal checks, bank checks, money orders,
negotiable investment securities or negotiable instruments in bearer form or
otherwise in such form that title thereto passes upon delivery.

"Equivalent
property" means property that may be readily converted into, or exchanged
for, United States or foreign currency or coin, including gold, silver or
platinum bullion or coins, diamonds, emeralds, rubies, sapphires or other
precious stones, stamps or airline tickets, or any other property that is
intended to be so converted or exchanged.

For purposes of determining whether
the state has proved the value of the (monetary instruments / goods / services /
property)1,
value shall be ascertained as follows: "Value" here means the market value of
the goods, services, or property at the time and place of the crime. "Market
value" means the price that would, in all probability, result from fair
negotiations between willing buyers and sellers at the time and place of the
crime; the probability being based upon the evidence in the case.

If you can determine the price the
property sold for at the time of the crime, then that is the controlling value.
If the market value cannot be determined, then you should consider the
replacement cost of the goods or services within a reasonable time after the
crime.

Monetary instruments, except those
having a readily ascertainable market value such as some public and corporate
bonds and securities, shall be evaluated as follows: The value of an instrument
constituting evidence of debt, such as a check, draft or promissory note, shall
be deemed the amount due or collectible thereon, such figure ordinarily being
the face amount of the indebtedness less any portion thereof which has been
satisfied. The value of any other instrument which creates, releases,
discharges or otherwise affects any valuable legal right, privilege or
obligation shall be deemed the greatest amount of economic loss which the owner
of the instrument might reasonably suffer by virtue of the loss of the
instrument. When the value of property or services cannot be satisfactorily
ascertained pursuant to these standards, its value shall be deemed to be an
amount less than fifty dollars.

Element 2 - Derived from
felonious conductThe second element is that the
defendant knew that at least one of the monetary instrument(s) (exchanged /
received) was derived from criminal conduct constituting a felony.2
"Felony" means a criminal offense committed in this state or another
jurisdiction punishable by death or a term of imprisonment exceeding one year.
A person acts "knowingly"
with respect to conduct or circumstances when (he/she) is aware that (his/her)
conduct is of such nature or that such circumstances exist. <See
Knowledge, Instruction 2.3-3.>

Element 3 - IntentThe third element is that the
defendant (exchanged / received) the monetary instrument(s) with the intent <insert
as appropriate:>

to conceal that the
exchanged monetary instrument or instruments (or equivalent property) is derived
in whole or in part from the criminal sale of a controlled substance.

that the exchange
aid a person in the criminal sale of a controlled substance.

that the exchange
aid a person to profit in the sale of a controlled substance.

that the exchange
benefit a person from the criminal sale of a controlled substance.

A person acts "intentionally"
with respect to a result when (his/her) conscious objective is to cause such
result. <See
Intent: Specific, Instruction 2.3-1.>

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant (exchanged / received in
exchange) a monetary instrument with a value exceeding ten thousand dollars for
one or more monetary instruments [or equivalent property], 2) (he/she) knew that
at least one of the monetary instruments (exchanged / received in exchange) by
the defendant derived from criminal conduct constituting a felony, and 3) the
defendant intended <insert specific allegations>.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of money
laundering in the first degree, then you shall find the defendant guilty. On
the other hand, if you unanimously find that the state has failed to prove
beyond a reasonable doubt any of the elements, you shall then find the defendant
not guilty.
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1
The value of money or credit is equal to its face value, and no special
instruction directing the jury on how to determine the value is necessary. The
instruction on determining the value is derived from General Statutes § 53a-121.